noteworthy recent rulings under company law

Noteworthy Recent Rulings under Company Law

Gaurav N Pingle,Practising Company Secretary

(E): [email protected](W): www.csgauravpingle.com

ICAI Pune Branch - Companies Law Refresher Course

mailto:[email protected]

http://www.csgauravpingle.com/

Scope & Coverage

Sat., April 15, 2017By CS Gaurav Pingle at ICAI Pune Branch - Companies Law Refresher

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Reference to particular provision of Cos. Act, 1956 &2013,

Rulings on Cos. Act:

a) Postal Ballot & BM via Video Conferencing,b) Duties & Liabilities of directors,c) Managerial Appointment,d) Certification of eForms,e) Issue of CA certificate in certain cases.

HC: Compulsory voting by postal ballot/e-voting not applicable to Court-convened meetings


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Bombay HC

Justice GS Patel

In the Scheme of Amalgamation

of

Wadala Commodities Ltd.

with

Godrej Industries Ltd.

Postal Ballot


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Extract

of

Sec. 110

of

Cos. Act,

2013

(1) Notwithstanding anything contained in this Act, a company:

(a) shall, in respect of such items of business as the CentralGovernment may, by notification, declare to be transacted only bymeans of postal ballot; and

(b) may, in respect of any item of business, other than ordinarybusiness and any business in respect of which directors or auditorshave a right to be heard at any meeting, transact by means ofpostal ballot,

in such manner as may be prescribed, instead of transacting suchbusiness at a general meeting.

(2) If a resolution is assented to by the requisite majority of theshareholders by means of postal ballot, it shall be deemed to havebeen duly passed at a general meeting convened in that behalf.

Rights of shareholders


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Clause 49(I)(A)

of SEBI circular

speaks of

‘Rights of

shareholders’,

which

includes:

Right to participate in and to be sufficientlyinformed on decisions concerningfundamental corporate changes;

Right to participate effectively and vote ingeneral shareholder meetings;

Right to ask questions to the board, toplace items on the agenda of generalmeetings, and to propose resolutions,subject to reasonable limits.

Issue involved in the case:


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Whether in view of Sec. 110 of Cos. Act, 2013 andSEBI Circular (May 21, 2013), a resolution forapproval of Scheme of Amalgamation can bepassed by majority of equity shareholders castingtheir votes by Postal Ballot (which includes e-voting) in complete substitution of an actualmeeting?

Justice GS Patel’s incisive commentary


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Heart of Corp. Governance lies transparency and well-established principle of indoordemocracy that gives shareholders qualified, yet definite and vital rights in matters relating tocompany functioning in which they hold equity.

Principal among these, is not merely right to vote on any particular item of business, so muchas the right to use vote as an expression of an informed decision. Therefore, Shareholder hasan inalienable right to ask questions, seek clarifications and receive responses before hedecides which way he will vote.

Schemes of Arrangement/Compromise are amended at a meeting itself. These amendmentscome from the floor or even perhaps from Board itself. Amendment is then put to vote.

In a postal ballot, no such amendment is possible. If we were to restrict ourselves to a postalballot, no shareholder or any director could ever suggest any amendment. Scheme wouldstand or fall only in its original form. This is contrary to the mandate of Sec. 391-394.

‘Called’ Meeting V/s ‘Ordered’ Meeting


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Even so Sec. 230 still speaks of ‘calling of a meeting’and ‘not merely putting the matter to vote’. It has tobe remembered that all schemes that are put tomeeting of shareholders are proposed schemes. Thismeans that they are subject not only to approval byvoting but also, possibly, to an amendment at themeeting itself.

Meetings for approval of Schemes u/s 391/394 of1956 Act are not ‘called’ by Co. Such meetings are‘ordered’ by the Court.

Dialogue & discourse are fundamental to making of every such informed decision


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Nothing could be more detrimental to shareholders’rights than stripping them of the right to question,the right to debate, the right to seek clarification;and, above all, the right to choose, and to choosewisely.

Vote is an expression of Opinion & it must reflect aninformed decision. Dialogue & discourse arefundamental to making of every such decision.

Conclusion


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Provisions for compulsory voting by postal ballot & by e-voting to exclusion ofactual meeting cannot & do not apply to ‘court-convened meetings’

At Court convened meetings, provision must be made for postal ballots & e-voting, in addition to an actual meeting.

Elimination of all shareholder participation at an actual meeting is anathemato some of the most vital of shareholders' rights,

It is strongly recommended that till this issue is fully heard and decided, noauthority or any company should insist upon such postal-ballot-only meeting tothe exclusion of an actual meeting.

Govt. & SEBI should appear before Court, when this matter is next taken up fora consideration of this issue.

NCLT: Quashes Board resolutions passed without Joint MD participation, despite availability on ‘Skype’


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NCLT, New Delhi

B.S.V. Prakash

Kumar, Judicial

Member

Rupak Gupta

Vs

U.P. Hotels Ltd.

LSI-1130-NCLT-2016-(NDEL)

Cos. (Meetings of Board & its Powers) Rules, 2014


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Rule – 3

Cos. (Meetings of Board and its

Powers) Rules, 2014

(Meetings of Board

through video conferencing

or other audio visual means)

Rule 3(3): Co. shall comply with foll.procedure, for convening & conducting BMsthrough video-conferencing or other audiovisual means.

Rule 3(3)(e): Director, who desire, toparticipate may intimate his intention ofparticipation through the electronic mode atbeginning of calendar year and suchdeclaration shall be valid for one calendaryear.

Obligation upon directors convening the meeting to provide every facility to directors asking video conference


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Rule 3 is meant for providing video-conferencing, indeedit is the duty of directors convening the Board meetingto inform other directors regarding the options availableto them to participate in video-conferencing mode orother audio video mode or other options available tothem.

It is the obligation upon directors convening the meetingto provide every facility to directors asking videoconference and enable them to participate in Boardmeeting.

NCLT’s observations on Board Meeting via video-conferencing


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“Sub-rule 3(e) only says that if intimation is given atbeginning of Calendar Year that will remain valid forentire Calendar Year. It is not said anywhere that if it isnot given at beginning of year, Video Conference facilityis not to be provided in that Calendar Year.

It does not mean that directors are not entitled for VideoConferencing if intimation is not given at beginning ofCalendar Year.

When a provision is read, it has to be read wholly and notin pieces”

HC: Upholds AoA clause requiring investor consent to initiate litigation; Discharges Azim Premji


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Bombay HC

Justice S. J. Kathawalla

Subhiksha Trading Services Ltd.,

R. Subramanian

V/s

Azim Premji

LSI-1129-HC-2016-(BOM)

Broad facts


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1. In an interview, Mr. Azim Premji said “investing inSubhiksha was a mistake and a lot of money has beensiphoned off”.

2. Rs. 500-Crore defamation suit was filed bySubhiksha and R. Subramanian (Promoter/MD)against Mr. Azim Premji.

3. Provision in AoA: Consent of VC Investor requiredfor: Commencement or discontinuance of anylitigation or arbitration which is material in the contextof the company’s business.

AoA provision (for initiating litigation) does not violate Contract Act


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Upheld Premji’s contention that AoA requires consent of atleast 1VC investors & rejected Subhiksha’s contention that such AoAclause is void as it violates Sec. 28 of Contract Act (‘Agreements inrestraint of legal proceedings, void’)

Article 17A of AoA does not contain a bar to filing of a suit, itsimply prescribes a condition precedent for filing the same.

There is nothing in law to prevent Co.’s AoA having suchprovision.

Defamatory suit seeking Rs. 500 crore in damages is certainly‘material’ in the context of co.’s business.

Rejects OL’s contention of ratifying failure to obtain board’s consent


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HC rejected OL’s contention that it can ratify suchfailure to obtain board’s consent as required byAoA and that it is entitled to prosecute the suit u/s441 and 457 of Cos. Act, 1956.

It would amount to an opportunistic misuse ofthe provisions of law

Sec. 196(3)(a) of Cos. Act, 2013


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Extract of

Relevant

provision:

No co. shall appoint or continue the employmentof any person as MD,WTD or Manager who:

(a) Is below the age of 21 years or has attainedage of 70 years:

Provided that appointment of a person who hasattained the age of 70 years may be made bypassing a special resolution in which case theExplanatory Statement annexed to the notice forsuch motion shall indicate the justification forappointing such person.

HC: Director turning 70 years not to attract automatic ‘mid-stream’ disqualification


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Bombay HC

Justice GS Patel

Sridhar Sundararajan (‘SS’)

Vs

Ultramarine & Pigments Ltd. &

Rangaswamy Sampath (‘RS’)

LSI-626-HC-2015-(BOM)

Broad Facts


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RS was appointed as CMD of listed co. on August 13, 1990. On May21, 1998, SS was appointed as director.

On August 1, 2012, RS was re-appointed as CMD for term of 5years till 2017. On same day, SS was also appointed as Joint-MD.

Cos. Act, 2013 was enforced w.e.f. April 1, 2014

RS attained the age of 70 years on November 11, 2014.

SS contended that “On the 70th birthday of RS, he earned himselfstatutory disqualification”

Interpretation of Single Judge


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Sec. 196(3) does not operate to interruptappointment of any Director made prior to cominginto force of 2013 Act.

It also does not interrupt the appointment of MDappointed after April 1, 2014 where at the date ofMD’s appointment / re-appointment was below theage of 70 years but crossed that age during histenure.

Contextual reading of the words in Sec. 196(3)


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Interprets Sec. 196(3), use of the words “Nocompany shall appoint or continue the employmentof….”, states that the words should be readcontextually.

Draws parallel reference from Sec. 269 of 1956Act, holds “there was no ‘discontinuance’ of MD atthe age of 70 years and the section applied only tohis appointment (including re-appointment)”.

‘70 years’ was never an automatic mid-stream disqualification


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70 years was never an automatic mid-streamdisqualification even under 1956 Act.

Single Judge relied on SC ruling in P. Suseela & Ors.Vs University Grants Commission (2015) wherein itwas held that “it is relevant to distinguish between anexisting right and vested right. Where a statuteoperates in future it cannot be said to be retrospectivemerely because within the sweep of it operation allexisting rights are included”

HC: Automatic disqualification trigger for directors turning 70, though appointment made pre-Cos Act, 2013


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Bombay HC

Justice VM

Kanade

&

Justice Dr.

Shalini

Phansalkar-

Joshi

Sridhar Sundararajan (‘SS’)

Vs

Ultramarine & Pigments Ltd. &

Rangaswamy Sampath (‘RS’)

[LSI-938-HC-2016-(BOM)]

“MD attaining 70 years would immediately be disqualified”


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Bombay HC’s Single Judge Order was quashed.

Division Bench held that disqualification for MD appointment on groundof age limit would act ‘automatically’

Thus, MD attaining 70 years would immediately be disqualified.

RS was disqualified from continuing as MD, unless he fulfilled therequirements of the proviso i.e. company has to continue his appointmentby a special resolution and, secondly, that resolution must state the reasonwhy the continuation is necessary.

Intention was to change earlier position by providing that person who hasbeen appointed as MD before he was 70 years old is prohibited fromcontinuing as MD once he has attained the age of 70.

“Language of Sec. 196(3)(a) is plain, simple & unambiguous”


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Rejected RS’s contention that Sec. 196(3)(a) is not applicable toMD’s appointment before April 1,2014, held “it would otherwiseretrospectively affect vested right of such MD and, secondly, thatthere is presumption against legislation operating retrospectively”.

Language of Sec. 196(3)(a) is plain, simple and unambiguous and itapplies to all MDs who have attained the age of 70 years and there isno distinction between MD who have been appointed before April 1,2014 and those after April 1, 2014.

Div. Bench rejected reliance on MCA Circular that clarifiedconditions specified in Schedule XIII Part – 1 of Cos. Act, 1956(requiring satisfaction only at the time of appointment).

HC: Director carrying competing business breaches fiduciary duty, imposes restriction, interprets Sec. 166


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Delhi HC

Justice

Manmohan

Singh

Rajeev Saumitra

Vs

Neetu Singh

[LSI-931-HC-2016-(DEL)]

Facts : Director commencing competing business


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Plaintiff (‘Husband’) & Defendant (wife) were holding50% shares in Paramount Coaching Centre Pvt. Ltd.(earlier, sole proprietary) Co. was in the business ofimparting education, training for various nationalcompetitive examinations;

Wife had approached Plaintiff to allow her to teachEnglish subject in the coaching institute;

Wife had poor financial condition. After 8-9 months,parties got married.

… Facts : Director commencing competing business


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After marriage, wife started hatching conspiracy to get her familymembers inducted in Co. and accordingly with necessary consents/ permissions were taken for conversion of Coaching Centre intoCo.

Simultaneously, wife incorporated OPC (‘Paramount ReaderPublication Pvt. Ltd.’) and started competing with the business ofParamount Coaching Centre Pvt. Ltd. i.e. diverting the business,staff, students and monies.

Parties disputed on TM – ‘PARAMOUNT’ & approached Civil Court.

Husband filed petition u/s 397-398 for mismanagement inParamount Coaching Centre Pvt. Ltd.

HC: Director carrying competing business breaches ‘fiduciary duty’


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HC held that wife has breached fiduciary duty u/s 166of Cos. Act, 2013 by initiating competing business;

Restrained her from using TM of ‘Paramount’

“She has not exercised her duty with due & reasonablecare, diligence & she was involved in the situation inwhich there was a direct interest that conflicted withco.’s interest, in order to gain advantage by herself andher relatives….. Being a Director, wife is guilty ofmaking undue gain and she is also guilty of carrying outcompeting business of co.”

“Sec. 166 is akin to common law right”


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Even if his/her co. may or may not be benefitted fromthe same, the said party is under a duty to pay over toco. which he or she has betrayed by disloyalty;

Interpreted Sec. 166, “in case director violates dutiesprescribed in Sec. 166, cause of action accrues in co.’sfavour. The said section is akin to the common law right.It is merely repository to Director’s fiduciary duties. Itdoes not apply to shareholder. Common law does notprevent plaintiff to take protection of common lawrights, even if statute excludes it specifically”.

Sec. 164 & 167 of Cos. Act, 2013


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Sec. 164 – Disqualifications forappointment of director.

Sec. 167 – Vacation of Office of director

Sec. 164(2) of Cos. Act, 2013


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Extract of

the relevant

provision

No person who is or has been a director of a co.which:

(a) has not filed financial statements or annualreturns for any continuous period of 3 FYs; or

(b)…..

shall be eligible to be re-appointed as a directorof that company or appointed in other companyfor a period of 5 years from the date on which thesaid company fails to do so.

Sec. 167 of Cos. Act, 2013 – Vacation of Office of Director


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Extract of

the relevant

provision

(1)The office of a director shall become vacant in case:

(a) He incurs any of the disqualifications specified inSec. 164;

(b) …

(c) …

(2)….

(3) Where all the directors of a company vacate theiroffices under any of the disqualifications specified insub-section (1), the promoter or, in his absence, theCentral Govt. shall appoint the required number ofdirectors who shall hold office till the directors areappointed by the company in the general meeting.

Kolkatta CLB: Prospective application of Sec. 164 &167


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Kolkatta CLB

Shri. Dhan

Raj, Member

Raj Shekhar Agrawal

Vs

Pragati 47 Development Ltd.

[LSI-985-CLB-2015-(KOL)]

Facts of the case


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Petitioners filed 397/398 petition alleging acts ofoppression/mismanagement in affairs of RespondentCo.

Petition was pending for adjudication;

Respondents filed an application praying for an orderof injunction restraining / declaring as non-estappointment of any Advocate-on-record/Counselsunder claimed authorization of erstwhile directors ofRespondent Co., as they had vacated their offices interms of Sec. 167(1)

... Facts of the case


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Respondent Co. submitted that all erstwhiledirectors vacated their offices in terms of Sec.167(1) read with Sec. 164(2), due to defaultcommitted by erstwhile directors in filing, thefinancial statements of Respondent Co. & and itssubsidiary cos. for 3 consecutive years.

CLB: Prospective application of Sec. 164 & 167


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Provisions of Sec. 164 & 167 have been notifiedw.e.f. April 1, 2014 and, hence, consequential actionu/s 167(3) accrues on non-filing of financialstatements for 3 years commencing from April 1,2014.

Erstwhile Directors continue to be validly andlegally appointed directors and hence, the saidBoard of Directors is competent to appoint theAdvocate by following the provisions of law.

Sec. 179 of Income Tax, 1961


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Sec. 179 of Income Tax,

1961

Liability of directors of

private company in liquidation

Notwithstanding anything contained in theCos. Act, 1956, where any tax due fromPrivate Co. cannot be recovered, then, everyperson who was a director of Private Co. atany time shall be jointly and severally liablefor the payment of such tax

Unless he proves that non-recovery cannotbe attributed to any gross neglect,misfeasance or breach of duty on his part inrelation to the affairs of Co.

Guj. HC: Pierces corporate-veil, Holds director liable for tax-dues of ‘de facto’ Pvt. Co.


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Gujarat High Court

Justice AkilKureshi

and

Justice A. J. Shastri.

Ajay Surendra Patel

Vs

Deputy Commissioner of Income-Tax

Broad Facts:


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Petitioner was appointed as Additional director of Hirak Biotech Ltd.(‘HBL’) and was holding 98.33% of the shareholding in HBL.

Income Tax Dept. raised demand for Rs. 240.82 lakhs on account of taxevasion which pertained to the year during which petitioner was actingas a director.

Dept. initiated recovery proceedings and made all possible efforts torecover impugned demand. It was then contended that substantialaccommodation entries were made during the period when petitionerwas director in HBL.

Dept. holding that HBL was set-up essentially for accommodationentries, invoked Sec. 179 of Income Tax Act.

Petitioner-Director filed a writ petition before Gujarat HC.

Facts leading to lifting of Corporate Veil


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Existence of huge financial transactions, serious default,total non-co-operation in Co.

HC observed that Co. appears to have been spearheaded byone of the directors only.

Serious defaults in financial transactions with J&K Bank &Ahmedabad People’s Co-Op. Bank of huge amounts

HC observed that “all these combination of circumstancesmakes this is a fit case to resort to a principle of lifting ofcorporate veil enshrined in Sec. 179 of IncomeTaxAct”.

HC’s observation w.r.t. “Accommodation entries”


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Main Object of the Co. was to carry on the business offloriculture, agriculture, horticulture etc.

However, the Co. had executed its business that of tradingand distribution of ice-cream quite de-hors from Main Object

HC observed that “It appears that Co. is set-up for differentpurpose than which is posed before the authority at the time ofincorporation. Therefore, the inference which has been raisedby Dept. that Co. is set up essentially for the purpose ofaccommodation entries might not be ignored, though attemptis made to establish contrary.”

History of Petitioner’s Background in the Co.


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Petitioner has resigned in Sep. within a short span

But, thereafter there was no substantial business of Co.

After that there is huge accrual of debts of Co.

And for recovery of that, even the properties have been auctionedand sold away under the steps of Securitization Act and

Therefore, it appears that after resignation of the petitionerwhat has been left with the company is huge liabilities only.

Huge demand to the extent of Rs. 240.82 lacs of Tax Revenueremained outstanding and despite aforesaid vigorous steps,nothing is recovered from Co. which has compelled the Dept. toinitiate action u/s 179 of Income Tax Act against all the responsibledirectors.

Factual matrix – Director’s gross neglect – Income Tax provisions invoked by HC


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Entire factual matrix would clearly indicate that thisposition of Co. in a gradual process to a virtual closureis on account of gross neglect, misfeasance or beach ofduty on the part of directors in relation to Co. affairs.

Therefore, the conditions which are contained inSection 179 before its invocation are appearing on theface of it which rightly visualized by the Dept. forpassing the order which is impugned in the petition.

Director’s duties u/s 166 vis-a-vis Corporate Governance


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Fiduciary obligation does not cease with Resignation.

Sec.166(3) of Cos. Act which spells out that director shallexercise his duties with due and reasonable care.

HC relied on SC’s ruling in N. Narayanan v. AdjudicatingOfficer, SEBI [AIR 2013 SC 3191], wherein it was held that“Failure of Corporate Governance on the part of directors ifthey failed to exercised due care and diligence and thereby,allowing fabrication of figures and false disclosure, theywould be liable for such omissions and commissions”.

Public Co. considered as ‘Private Co.’ for Sec. 179 of Income Tax Act


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Close look at Co. affairs, the manner in which affairs proceeded with, all indicatethat in actual terms the Co. has not acted as Public Ltd. Co. in true sense;

It is also revealing that during tenure of petitioner, huge cash flow is deposited andpractically use of cash flow deposit to be looked into substantially the Co. is used forobject for which it has not been set-up;

There is no involvement of public in the share capital or in any form of asset andthere is no share subscription issued from public by Co. in question;

Therefore, practically the Co. appears to have systematically operated as if it is aprivate concern. On the contrary, a Public limited Co. has to act more in responsiblemanner than Private Ltd. Co.

CLB: Serious lapses in filing cannot be rectified by Sec. 111 petition, observes mala fide


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CLB Mumbai

Bench

Ashok Kumar

Tripathi, Judicial

Member

Badve Engineering Ltd., In re

[LSI-83-CLB-2014-(MUM)]

Facts of the case


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Petitioner Co. had allotted Equity shares to its existing shareholders in itsboard meeting held on different dates.

Petitioner Co. filed Form 2 with wrong details:

a) No. of Eq. Shares was wrongly filled as 7,00,000 instead of 1,400

b) No. of Eq. Shares was wrongly filled as 93,00,000 instead of 18,600

c) Amount of premium was also not filled in the Form 2.

Petitioner Co. prayed that for rectifying register of members, with ajustification that “Mistake in filling Form No.-2 was caused due to oversightand not with wilful intention”

Serious lapses in filing cannot be rectified by Sec. 111 petition


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Version of Petitioner-Co. claiming an inadvertenttypographical error in e-Forms is extremely doubtful;

Petitioner has approached CLB with unclean hands.Petition seems collusive & filed with ulterior purpose.

Such major mistakes cannot be repeated one afteranother and go unnoticed by signatories who havesigned e-Forms

Error in filing eForm 2 can be rectified by capital reduction procedure


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Petitioner co. cannot reduce paid-up sharecapital when filing Annual Return with ROC,without complying with procedure u/s 100 of Cos.Act, 1956 & without seeking confirmation of HC.

CLB forwarded copy of its order to Director(Inspection), MCA & SEBI for necessary action.

HC: ‘Gross negligence’ ‘Professional Misconduct’ of Statutory Auditorissuing false IPO certification, costs him ICAI members


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Telangana & AP High

Court

Chief Justice Ramesh

Ranganathanand

Justice M. Satyanarayan

a Murthy

ICAI Vs Mukesh Gang

[LSI-1299-HC-2016-(AP)]

Broad Facts of the case


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Practising CA was the Statutory Auditor of an unlistedpublic co. (Co. was in the process of making an IPO),

PCA had certified the receipt of entire promoters’contribution when only 15% of ‘subscription money’was actually received, and cheque for remainingamount had bounced,

He contended that he had verified only co.’s bankbook (which showed that cheques were received), notexpecting the promoters’ cheques to bounce based ontheir track record/reputation.

…. Broad Facts of the case


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ICAI’s Disciplinary Committee had framed chargesand after following prescribed procedure, hadfound Respondent guilty of misconduct CA Act,

Disciplinary Committee had forwarded its reportto ICAI’s Central Council, who accepted thefindings and moved HC to remove Respondent’sname from ICAI roster

HC: If false certificate is issued by Auditor, it would amount to his failure to discharge his statutory duties


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HC stated that IPO Prospectus is a special document of the Co.and it is Auditor’s duty to certify receipt of entire sums duetowards promoters contribution before shares are offered to thepublic at large.

If false certificate is issued by the Auditor, it would amount to hisfailure to discharge his statutory duties, as he must be presumed tobe aware of the consequences that flow from such gross negligenceof a false certification

CA is a professional whose expertise in accountancy isacknowledged….Certificate issued by an Auditor has its own impacton the public at large, as it is largely on the basis of this certificatethat the general public subscribe to the shares of co.

HC decoded ‘certification’


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HC interpreted the term ‘certification’, and opined that,“Certification is a formal procedure by which an accreditedor authorized person or agency assesses and verifies theattributes characteristics, quality, qualification or status ofindividuals or organisations, goods or services….Certificationrefers to the confirmation of certain characteristics of anobject, person, or organization”;

It is imperative that utmost care and caution is exercised inissuing such certificates, and the objectivity, integrity,reliability and credibility of the information therein isensured”

HC: CA’s False certification has enabled Co. Promoters tosquander public money


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HC: False certification by the respondent has enabledthe promoters of the company to squander publicmoney, on inducing the general public to subscribe tothe share capital of the company

HC: Taking a lenient view, or exonerating suchprofessionals, would encourage others to indulge insimilar acts, and completely erode the faith of thegeneral public in the impartiality and integrity of themembers of the Institute, and bring the Institute itselfinto disrepute

Conclusion drawn by HC


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HC suspended Chartered Accountant’s ICAImembership for a period of 3 years (from Nov. 1,2016 to Oct. 31, 2019)

Q & A Session

Sat., April 15, 2017

60

By CS Gaurav Pingle at ICAI Pune Branch - Companies Law Refresher Course

Thank you MembersThank you ICAI, Pune for the opportunity!

Sat., April 15, 2017

61

By CS Gaurav Pingle at ICAI Pune Branch - Companies Law Refresher Course

noteworthy recent rulings under company law

Documents